ML20053A832
| ML20053A832 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/24/1982 |
| From: | Chapman D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20053A827 | List: |
| References | |
| NUDOCS 8205270333 | |
| Download: ML20053A832 (15) | |
Text
{{#Wiki_filter:; t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1 BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD In the Matter of ) TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY, -et al. ) 50-446 ) (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses) TESTIMONY OF DAVID N. CHAPMAN REGARDING THE QA/QC ORGANIZATION AT COMANCHE PEAK Ol. Please state your name, residence and educational and professional qualifications. A1. My name is David N. Chapman. I am employed by Texas Utilities Generating Company ("TUGCO") in the position of Manager, Quality Assurance. I reside in Richardson, Texas. A statement of my educational and professional qualifica-tions was received into evidence at Transcript p. 509. 02. What is the subject of your testimony? A2. My testimony addresses the Quality Assurance / Quality Control ("QA/QC") Organization for Comanche Peak during the construction phase. Q3. What is the role of the Manager, Quality Assurance? A3. My role is to direct the operations of the Quality Assurance Division. Q4. What qualifications are required of the individual assigned to be Manager of Quality Assurance? A4. The Manager of Quality Assurance must meet stringent 8205270 M
i . qualification criteria in terms of both education and experience. The Manager must have (at least) a bachelor of science degree from an accredited college in an engineering or science discipline and be a registered professional engineer. He must also have (at least) ten years experience in design, construction, and/or opera-tion of power plants and a demonstrated managerial ability. As for experience in the OA area, he must have a knowledge of OA requirements for nuclear plants including a minimum of one year experience in the implementation of a nuclear QA program. I meet all these requirements. I have been Manager, Quality Assurance, for TUGCO since September 1976. 05. What organization has ultimate responsibility for the OA/QC organization at Comanche Peak? / A5. From the beginning of the Comanche Peak project, TUGCO as the lead Applicant has maintained ultimate responsibility i for the construction OA program at Comanche Peak. In f this position, TUGCO carefully monitors and/or conducts all aspects of the OA program to assure that construc-tion of the facility is performed in conjunction with l an effective QA/QC program. TUSI 1/ is designated by [ TUGCO to have the authority to conduct the required -1/ Texas Utilities Services, Inc. ("TUSI") is the engineering service organization for Texas Utilities Company. 1 l r
. engineering, design, procurement, and construction technical support activities for CPSES, including implementation of the OA program at the site. 06. What organization manages the OA/OC organization at Comanche Peak? A6. Initially, Brown & Root, Inc., the Construction Manager / Constructor, managed the OA/OC program applicable to work performed by them and their' contractors for the early stages of the project. Brown & Root met its responsibilities in this role. As the project progressed and became more complex, TUGCO determined that a more aggressive program with even more direct involvement by TUGCO was essential to meet TUGCO's OA/OC goals for the project. In July 1977, TUGCO initiated action requiring TUGCO involve-ment in all Brown & Root vendor release inspections. ,t Subsequently, upon assessing the success of such direct involvement by TUGCO, it was determined that TUGCO would provide overall technical m'anagement of OA/OC functions for CPSES except for those activities under the jurisdiction of the ASME Boiler and Pressure Vessel Code, Section III, Division 1 (ASME Code). Although Brown & Root retained functional managment of ASME Code work under their QA program, TUGCO continued to have the ultimate responsibility for all such work.
.~ . 07. Did the change in management for the QA organization enhance the CPSES QA program? A7. The measures taken to restructure the QA organization at Comanche Peak enhanced the quality function for the project. The excellent relationship developed between OA, QC, and construction personnel has resulted in a teamwork approach that focuses attention on identi-fying and solving problems. In sum, the measures have resulted in a OA/QC Organization tailored specifically for and responsive to the needs of the Comanche Peak project. 08. What other organizations perform QA functions at Comanche Peak? A8. In addition to TUGCO and Brown & Root, Gibbs & Hill, as Architect-Engineer, and Westinghouse Electric Corporation (" Westinghouse"), as nuclear steam supply system ("NSSS") j supplier, provide QA programs for principal activities within the scope of their responsibilities. Gibbs & Hill provides TUSI with certain engineering, design, and procure-ment services as requested, and provides the QA program for QA activities within its scope of work. Westinghouse pro-vides the QA program governing work done on the NSSS struc-tures, systems and components. As discussed above, Brown & Root manages the QA program for ASME Code work and may . [1
. perform other QA functions as requested by the TUGCO Quality Assurance Manager. An organization chart for the project QA organization is presented as Attachment 1. 09. To what extent does the TUGCO QA organization manage the QA responsibilities for the project? A9. The TUGCO QA organization was established to provide effective control of safety-related activities at Comanche Peak. This control extends to all organiza-tions performing services affecting nuclear safety during the engineering, design, procurement, and con-struction phases. The TUGCO QA organization exercises direct functional manegement over all activities ex-cept ASME Code work, and exercises control over all activities, including ASME Code work. Q10. What is the organizational structure of the TUGCO QA Division? A10. The TUGCO QA Division participating in design and construction of Comanche Peak is shown in Attachment
- 2. This chart illustrates the organizational structure and lines of reporting for each organization.
These are described in the corresponding sections. The TUGCO QA Division is responsible for developing and assuring the implementation of the CPSES QA program for design and construction. The QA Division is headed by the Manger, Quality Assurance. He reports directly to the Vice President, Nuclear. This independent reporting arrangement assures that safety considerations
. are not influenced by cost and scheduling. He reviews the performance of the QA program on a regular basis with the Vice President, Nuclear, reporting on quality status and the overall effectiveness of the OA program. Oll. What additional duties does the Manager, Quality Assurance have? All. The Manager, Quality Assurance has the duty and authority to identify quality-related problems; to initiate, recommend or provide solutions; and to verify the implementation and effectiveness of solutions. He has authority to "stop work" in the engineering, design, procurement, and construction phases. He also supervises the Site QA Supervisor at Comanche Peak who is responsible for assuring the implementation of the OA Program on a daily basis at the site. 012. Who is responsible for implementing design and construc-tion quality requirements for Comanche Peak? Al2. For the Comanche Peak project, the Vice President and Project General Manager, Texas Utilities Services, Inc. ("TUSI"), coordinates and controls engineering, procurement, and construction activities. He is responsible for cost and schedule and for implementing i design and construction quality requirements. The Vice President and Project General Manager reports to the Executive Vice President of TUSI. The Manager, Quality Assurance, is responsible for verifying that quality requirements have been implemented. H 1 n
. Reporting to the Vice President and Project General Manager is the Engineering and Construction Manager who is responsible for project design, engineering and procurement. These activities are normally delegated to Gibbs & Hill, Inc., Westinghouse and other contractors / vendors. TUSI, however, retains overall responsibility for these activities and performs design functions as necessary. Q13. What role does Gibbs & Hill play in the CPSES QA program? A13. TUGCO has retained Gibbs & Hill to provide experienced personnel as needed to assist TUGCO OA with the overall OA program. The Gibbs & Hill Project Manager directs the engineering, design, and procurement functions and establishes and maintains project relations with TUSI. The Project Manager is responsible for assuring that established procedures are implemented. The l Project Manager has the authority to "stop work" on engineering and design activities performed by Gibbs & Hill. Q14. How is the Gibbs & Hill OA organization for Comanche Peak structured? A14. The Gibbs & Hill OA Department, headed by the OA Manager, assures the implementation of the Gibbs & Hill QA program through engineering and design audits. Further, the OA Manager is responsible for development
. of detailed QA procedures. He can require the Project Manager to exercise his "stop work" authority. Further the QA Manager audits the activities of independent Design Review engineers who determine compliance with safety-related design concepts. The QA Department is completely separate and functions independently from those persons or groups having specific project design, scheduling, or budgetary responsibilities. Independence is maintained further by having the QA Manager report to the Vice President. is a chart of the Gibbs & Hill QA Organization. 015. What QA functions does Brown & Root perform? A15. Brown & Root provides the QA program for ASME Code construction and other QA functions as may be requested j by the TUGCO QA Manager. Brown & Root's OA personnel have the freedom to identify quality problems, to recommend solutions, and to verify that solutions have been implemented. This organization has sufficient l l independence and authority to carry out the program in an orderly, effective manner. It employs a documentation system which provides necessary record retention and access capability. The Brown & Root QA organization for its Houston office and for site activities is shown in Attachment 4. Ol6. Who is responsible for the Brown & Root QA program? i I r
. A16. The Brown & Root Project OA Manager is responsible for implementation of the B&R QA Manual requirements in the fabrication and installation of ASME Code, Section III, Division 1 systems and components. Direction of all site OA and OC activities other than ASME Code work is provided by the TUGCO Site QA Supervisor. For technical and administrative supervision of ASME Code work and for administrutive supervision in all other areas, the Brown & Root Project GA Manager reports to the Brown & Root OA Manager in Houston. 017. What are the interfaces between the participating organizations at Comanche Peak? A17. TUGCO/TUSI has established the following interfaces of the participating organizations in the QA program at Comanche Peak: 1. Brown & Root Project GA Manager reports to the Brown & Root QA Manager for technical and administrative supervision of ASME Code work, and for administrative supervision in all other areas. Direction of the Brown & Root Project QA Manager in areas other than ASME Code work is provided by the TUGCO Site OA Supervisor. 2. Construction site inspections are performed under the direction of TUGCO OA and Brown & Root OA (ASME Code work only) or by contractor or subcontractor. 3. Periodic audits and surveillances of site OC and construction activities are performed by TUGCO OA to verify conformance. 4. Vendors are required to provide internal, independent OA programs unless working under the TUGCO OA program.
o 5. TUGCO OA and/or its consultants or agents conduct vendor audits, surveillance and inspections to verify performance. 6. Westinghouse provides the OA program for NSSS components. 7. Gibbs & Hill provides the OA program for design and engineering. 8. TUGCO OA periodically audits Westinghouse, Gibbs & Hill, Brown & Root and internal TUGCO/TUSI safety-related activities. 9. Brown & Root GA periodically audits their ASME OA program onsite, as required. 018. What are the principal records which document the involvement of OA in Comanche Peak construction activities? A18. The Inspection Report ("IR") is the primary record documenting OA involvement in non-ASME construction l activities. It contains the attributes and results of '/ the inspections conducted of the various non-ASME construction activities. The Weld Data Cards ("WDC") and Nondestructive Examination ("NDE") Reports arc the l principal records which document the involvement of OA in Comanche Peak ASME construction activities. Unsatis-factory conditions that cannot readily be corrected in l l the field are documented on either a Nonconformance Report ("NCR") or Field Deficiency Report ("FDR"). The NCR is the form used to document formally a noncon-forming condition that requires further action by the I 1 l l e
o . project construction and/or engineering organizations. The FDR is the form used to identify and resolve relatively minor matters discovered through routine inspection. In addition, a Corrective Action Request (" CAR") can be issued to document the need for correc-tive action involving more important or repetitive conditions. O.19. What is your overall assessment of the OA/QC organiza-tion for Comanche Peak? A.19. In summary, the OA/QC organization established for the construction of the Comanche Peak facility has been carefully structured, and it functions success-fully to provide assurance that applicable codes, standards, and regulatory requirements are met. We established and have maintained a OA program that fully meets the requirements of the construction permits for Comanche Peak and Apendix B of 10 C.F.R. Part 50. This has resulted in an excellent overall record of quality assurance and quality control at Comanche Peak, and provides a high level of assurance that construction of Comanche Peak has been and will l ba in conformity with all applicable requirements. I
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